The Eighth Circuit Court of Appeals affirmed a lower court's summary judgment for Iowa police officers and local government entities in a civil rights lawsuit filed by two individuals who had previously won suppression of evidence in their criminal case.

In *Valdivia v. Porsch* (8th Cir. 2026), the court ruled against plaintiffs Rene Valdivia and Alexis Free, who sued under 42 U.S.C. § 1983 and state law after criminal charges against them were dismissed. The defendants included officers Derek Porsch, Gabriel Christensen, Derick Seaton, Coby Gust, and Todd Johnson, along with the City of Audubon, Iowa, and Audubon County, Iowa.

The incident began on Oct. 8, 2022, when Officer Porsch observed a vehicle without an operating license plate light during his night patrol. According to court records, Porsch made a U-turn to follow the vehicle but did not activate his emergency lights. After the car made several turns, it pulled over on a residential street.

At that point, Free exited the passenger side and began running. Porsch approached the driver's side and spoke with Valdivia, who explained that Free wanted to visit a sick aunt. Porsch then left to search for Free, circling the block before returning to the area where she had fled the vehicle.

The circumstances surrounding the arrest and evidence seizure led to criminal charges being filed against both Valdivia and Free in state court. However, their legal strategy proved successful when they filed motions to suppress evidence obtained during the arrest. The state court granted these motions, finding constitutional violations in how the evidence was collected.

Following the suppression ruling, all criminal charges against both defendants were dismissed. This victory in criminal court then formed the foundation for their federal civil rights lawsuit under Section 1983, which allows individuals to sue government officials for constitutional violations committed under color of law.

The civil rights complaint targeted multiple officers involved in the incident, as well as the municipal entities that employed them. Section 1983 claims require plaintiffs to demonstrate that government actors violated their constitutional rights while acting in their official capacity. The inclusion of municipal defendants suggests the plaintiffs alleged institutional policies or customs that contributed to the constitutional violations.

However, the U.S. District Court for the Southern District of Iowa granted summary judgment in favor of all defendants. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. This ruling indicated the district court found the defendants were entitled to prevail even when viewing the facts in the light most favorable to the plaintiffs.

The plaintiffs appealed this decision to the Eighth Circuit, arguing the district court erred in granting summary judgment. The three-judge panel, consisting of Circuit Judges Loken, Kelly, and Erickson, heard the case on Sept. 16, 2025.

In their Jan. 6, 2026 opinion authored by Circuit Judge Kelly, the appeals court affirmed the district court's ruling. The affirmance means the Eighth Circuit agreed that the defendants were entitled to summary judgment on both the federal constitutional claims and state law claims.

The ruling represents a common scenario in civil rights litigation where successful suppression of evidence in criminal proceedings does not automatically translate to civil liability. While the state court found constitutional violations sufficient to suppress evidence under the exclusionary rule, the standards for civil liability under Section 1983 include additional requirements such as clearly established law and qualified immunity defenses for individual officers.

For municipal liability, plaintiffs must demonstrate that constitutional violations resulted from official policies, customs, or deliberate indifference by policymaking officials. These standards often prove difficult to meet, even when underlying constitutional violations occurred.

The case highlights the distinction between criminal and civil consequences for alleged police misconduct. While the exclusionary rule serves to deter constitutional violations by suppressing illegally obtained evidence, Section 1983 serves the different purpose of providing compensation to victims and deterring future violations through monetary damages.

The Eighth Circuit's decision is final unless the plaintiffs petition the Supreme Court for review through a writ of certiorari. However, the Supreme Court only hears a small percentage of cases appealed to it, typically those involving important legal questions or conflicts between circuit courts.

This outcome underscores the challenges plaintiffs face in Section 1983 litigation, where procedural hurdles and immunity doctrines often prevent recovery even when constitutional violations may have occurred. The case serves as a reminder that success in criminal proceedings does not guarantee corresponding success in civil rights litigation against the same government actors.